HGF has the highest possible ambitions when it comes to transparency, honesty and responsibility. In accordance to this, we expect employees and partners who suspect foul play in any of HGF's activities to come forward and report it.

Employees are often the first ones to discover suspicious misconduct or unethical behaviour within an organisation. According to HGF's Code of Conduct and HGF's Procedure for Health and Safety, employees shall report any suspicion of misconduct or unethical behaviour to their immediate superior. If, however, and employee is hesitant to do so because of fear of harassment or retribution, then the Whistle-blower system provides an alternative means for reporting.

The purpose of this Whistle-blower policy is to offer all employees an alternative channel for reporting suspected misconduct or unethical behaviour without the risk of retribution, discrimination or other consequences. The Whistle-blower system is designed to be used in the event of serious misconduct and as an alternative to the normal reporting procedure.

This policy is applicable to all HGF employees including subsidiaries. The policy also entails a commitment from the company to immediately deal with and thoroughly investigate reports of wrongdoing by HGF or by its employees, consultants and suppliers, and adopt suitable actions. The Whistle-blower system allows all employees to act in a responsible way to maintain HGF's reputation and society's trust in our company. The purpose of the policy is to ensure that all suspected misconduct or unethical behaviours are dealt with in a torrett way.

What is Whistle-blowing?
Whistle-blowing is an alternative way to report suspected misconduct or unethical behaviour to make the company's top management aware of the situation.

What is included in the Whistle-blower policy?
The policy includes serious misconduct that could have a negative effect on the company's business and that cannot be reported via the normal reporting procedures. Examples:
• Illegal activities
• Financial fraud (for example false or devious bookkeeping, skipping financial control procedures, embezzlement)
• Bribes and corruption (for example conflict of interest, bribes, unethical sponsorship and donations, unethical gifts)
• Breaching fair competition laws (for example exchange of sensitive information concerning prices, cartel practices and tacit collusion)
• Serious threats to the environment, health and safety
• Other activities that can be considered seriously inappropriate (for example discriminating work practices, the use of child labour, violation of human rights)

What is not included in the Whistle-blower system?
• Alcohol and drug abuse
• Smaller thefts
• Less serious health and safety problems
• Crimes or offences committed by employees outside the Management teams

These and other minor cases of misconduct shall be reported via the normal reporting channels to the immediate superior.

Who is protected?
The company will make sure that all reports on suspected misconduct and unethical behaviour will be correctly and discretely dealt with. Any employee who comes forward and reports misconduct within the guidelines of this policy will be protected if he or she:
• acts in good faith
• believes the information is substantially correct
• does not act with malice and reports false accusations
• does not try to achieve personal and/or financial gain

The company will act so as to minimise the potential difficulties that may arise when an employee reports a suspected misconduct. If the employee is required to appear as a witness in a criminal trial, then the company will provide legal counselling for this purpose.

Where to report?
He or she who has a complaint or suspects misconduct in the company's activities should as a first option contact his or her superior, or the manager who is in charge of the affected department. Depending on the nature of the misconduct and the person under suspicion, the aforementioned
manager will decide if the care is to be presented to the Company's Management Team. As a second option, and as an alternative to the normal reporting channels and procedure, complaints can be presented to:

The Chairman of the Board
Jan Johansson
+46 705 92 0605

The company's legal representative
Carl-Johan Krusell
+46 70 989 65 02

How will the information be handled?
After having received the information, Mr. Johansson or Mr. Krusell will decide if it is of such nature that it should be handled within the Whistle-blower system. If it is not of such nature, the information will be erased. If it is, then an initial investigation will be carried out to decide whether or not to initiate a more extensive investigation. If urgent actions are required, then these will be implemented without waiting for the investigation to conclude.

All documentation and filing of personal information will be done at the company's headquarters in Halmstad, Sweden.

Confidentiality and anonymity
The company will, as far as possible, respect the whistle-blower's requests for confidentiality. It could, however, be difficult to follow up and verify anonymous tips.

False and malicious accusations
HGF's goal is to uphold the highest possible degree of honesty and trustworthiness in its business activities. The company will ensure that adequate resources will be assigned to investigate each report of misconduct. It is, however, important that the person who is considering filing a report makes sure that the accusations are legitimate. No accusations may be submitted in malice or knowing that they are false. The company will consider the handing in of deliberately false and/or malicious accusations as a serious disciplinary offence.

The right to information
When the information ("Data") has been gathered, the person or persons involved ("the Data Subject/-s") will be informed. If it is not possible to hand over Data immediately, e.g. if this would jeopardise an upcoming investigation, the company will do so once the risk is no longer there. The Data Subject shall be informed as soon as possible, and under no circumstances no later than the point in time when the Data concerning the Data Subject is used. The Data must also be given to anyone who asks the company if there is registered Data about him or her. Such Data shall be handed out within a month and never later than four months after the request was made. The Data that is handed out upon request may not reveal the identity of the person who has submitted the information.